Do you use nitrogen?

[Gatorman]

AVBUG. you are my hero.

I read this thread when it first started (thinking that it should be on the mechanic's forum) and I knew it was going to be a great thread.

Thank you for setting them straight - and by the letter by gosh!


Now, if they will take the time to read and absorb the info.......the next question will be "Where is a good place for BBQ?"

 

[ackattacker]

While 14 CFR 43 Appendix A cites removal, installation, and repair of landing gear tires as preventative maintenance (assuming no complex assembly operations are required), servicing of the tire is not listed.

While nobody has every claimed that the regulations make perfect sense, are you going to seriously argue that I could take the tire off a Piper Arrow, repair it, repack the wheel bearings, reinstall-it, fill the strut with nitrogen (servicing of struts is listed as preventative maintenance), and then I'd have to call an A&P over to put some air in the tire? I think a reasonable person would assume that the authority to "repair" a tire includes the authority to service it with air (or nitrogen if required).

14 CFR 43 Appendix A doesn't cite replenishing engine oil. It does cite replenishing hydraulic reservoirs. We better warn everybody to stop adding their own oil to their engines. What about adding fuel... you know "servicing the fuel tanks?" That's not listed either. Lot's of AD's apply to refuelling. It's very dangerous, people get killed all the time. I don't see mechanics coming out to refuel aircraft though.

Obviously if an AD specifies a mechanic then you need a mechanic. In the absence of that, I stand by my statement that a part 91 pilot can fill his or her own tires with nitrogen, if nitrogen is called for. I didn't say it was necessarily wise or safe. Plenty of "certified mechanics" have killed themselves by attaching unregulated 3000 psi nitrogen bottles to aircraft wheel assemblies.

 

[ackattacker]

I did some followup research and question asking.

I believe the problem is in how you interpret the intention of Appendix A. Appendix A is a list of "Allowable" pilot-performed maintenace items, which are then specifically excluded in air-carrier operations. So the point is, is it a list of ALL the things you (part 91 pilot) CAN do, or is at list of things which an (air carrier) pilot CANNOT do? In general, "routine servicing" is NOT maintenance. Hence "servicing the fuel", "servicing the oil", and even yes "servicing the tires" is not even considered maintenance at all, UNLESS it is specifically listed in Appendix A, which makes it a "maintenance" item.

Those items which are listed in 14 CFR 43 Appendix A as "servicing" are to be interpreted as service items which ARE considered maintenance and hence CANNOT be pilot performed under 135, 129, and 121. Hence a pilot under 135 cannot add hydraulic fluid, but CAN add engine oil. (So long as the procedure doesn't require the removing of a cowl, which would be "preventative maintenance")

Under this interpretation even a 135 pilot CAN service the tires, provided it doesn't involve any removal of cowls or such. Avbug, if you can prove me wrong go for it.

 

[avbug]

Under this interpretation even a 135 pilot CAN service the tires, provided it doesn't involve any removal of cowls or such. Avbug, if you can prove me wrong go for it.

That would be a FAA Chief Legal Counsel Interpretation, would it? Or your opinion? Prove your opinion wrong? Your opinion stated above lacks so much understanding of the regulation, in particular maintenance regulation, that there's no need to "prove" anything.

Appendix A is a list of "Allowable" pilot-performed maintenace items,...

No, it's not. It's a list of preventative maintenance items, to define the performance standard set forth by 14 CFR 43.13, as described in my prior posts. Merely because something is listed in Appendix A, subpart C, preventative maintenance, does not mean a pilot may perform it. Numerous additional requirements exist, as I have already outlined, and as you have clearly missed. Read again.

...which are then specifically excluded in air-carrier operations.

Are they?

§ 43.3 Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations.

(d) A person working under the supervision of a holder of a mechanic or repairman certificate may perform the maintenance, preventive maintenance, and alterations that his supervisor is authorized to perform, if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation. However, this paragraph does not authorize the performance of any inspection required by Part 91 or Part 125 of this chapter or any inspection performed after a major repair or alteration.

(f) The holder of an air carrier operating certificate or an operating certificate issued under Part 121 or 135, may perform maintenance, preventive maintenance, and alterations as provided in Part 121 or 135.

(g) Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

(h) Notwithstanding the provisions of paragraph (g) of this section, the Administrator may approve a certificate holder under Part 135 of this chapter, operating rotorcraft in a remote area, to allow a pilot to perform specific preventive maintenance items provided -
(1) The items of preventive maintenance are a result of a known or suspected mechanical difficulty or malfunction that occurred enroute to or in a remote area;
(2) The pilot has satisfactorily completed an approved training program and is authorized in writing by the certificate holder for each item of preventive maintenance that the pilot is authorized to perform;
(3) There is no certificated mechanic available to perform preventive maintenance;
(4) The certificate holder has procedures to evaluate the accomplishment of a preventive maintenance item that requires a decision concerning the airworthiness of the rotorcraft; and
(5) The items of preventive maintenance authorized by this section are those listed in paragraph (c) of Appendix A of this part.
(i) Notwithstanding the provisions of paragraph (g) of this section, in accordance with an approval issued to the holder of a certificate issued under part 135 of this chapter, a pilot of an aircraft type-certificated for 9 or fewer passenger seats, excluding any pilot seat, may perform the removal and reinstallation of approved aircraft cabin seats, approved cabin-mounted stretchers, and when no tools are required, approved cabin-mounted medical oxygen bottles, provided -
(1) The pilot has satisfactorily completed an approved training program and is authorized in writing by the certificate holder to perform each task; and
(2) The certificate holder has written procedures available to the pilot to evaluate the accomplishment of the task.

So the point is, is it a list of ALL the things you (part 91 pilot) CAN do, or is at list of things which an (air carrier) pilot CANNOT do?

Both, and neither. Do a little more research.

In general, "routine servicing" is NOT maintenance.

Too wrong, mate. In many cases, routine servicing certainly is maintenance. In some cases, routine servicing may require a maintenance record entry, such as putting oil in a turbine engine. Any case of AD compliance requires a maintenance log entry, as does any inspection or required inspection.

Hence "servicing the fuel", "servicing the oil", and even yes "servicing the tires" is not even considered maintenance at all, UNLESS it is specifically listed in Appendix A, which makes it a "maintenance" item.

Quite incorrect. Part 43 Appendix A does not presume to identify what constitutes maintenance; it specifically identifies some items which under some circumstances constitute preventative maintenance. Not all items identified as preventative maintenance under Appendix A are always preventative maintenance. You cited removing a cowl; this becomes a complex disassembly in many cases, and does not permit the operation to fall under the guise of preventative maintenance, even though it may be listed. Again, more applies than a simple reading of this one appendix.

An item does not need to be listed in Appendix A to be a maintenance item, nor to be an item or function that requires a particular level of certification (eg, Mechanic, Repairman, etc) to execute. Your understanding in this area is severely lacking, and could quite easily get yourself, or someone who chooses to listen to you, into serious trouble.

You seem to fail to understand that frequently understanding a particular regulation or concept necessitates understanding multiple other regulations and concepts; more than one regulation frequently applies. Attempting to understand the concept on the basis of a single regulation is a dangerous approach which may place you in legal and physical jeopardy.

 

[avbug]

Those items which are listed in 14 CFR 43 Appendix A as "servicing" are to be interpreted as service items which ARE considered maintenance and hence CANNOT be pilot performed under 135, 129, and 121.

Again, completely incorrect. Upon what basis have you determined that servicing becomes maintenance, whereas "routine servicing" is not maintenance? Your attempt to understand the regulation is disjointed and nonsensical. Items listed under Appendix A may or may not require the services of a certificated mechanic. The word "servicing" has no bearing on the topic, and does not define what constitutes preventative maintenance, nor does it have any bearing on what a pilot can or cannot do. Further, those terms, and your useage thereof, have no bearing upon their applicability to certificate operations such as Part 135.

Hence a pilot under 135 cannot add hydraulic fluid, but CAN add engine oil. (So long as the procedure doesn't require the removing of a cowl, which would be "preventative maintenance")

Again, a concept you have dreamed up, with no basis in regulation or fact. Why exactly might a pilot not be able to add H-5606 fluid, yet be fully legal in adding Turbine Type II oil, instead? Particularly with respect to maintenance items, a certificate holder may obtain authorization to enable a crewmember to perform almost any operation, so long as all the requirements to perform that operation are met and the operation is conducted in accordance with that authorization. This could include fluids, gasses, removal and installation of seats, panels, plugs, gauges, etc. The ability of a certificate holder to obtain this authorization lies in the abiity of the certificate holder to ask for it.

While nobody has every claimed that the regulations make perfect sense, are you going to seriously argue that I could take the tire off a Piper Arrow, repair it, repack the wheel bearings, reinstall-it, fill the strut with nitrogen (servicing of struts is listed as preventative maintenance), and then I'd have to call an A&P over to put some air in the tire? I think a reasonable person would assume that the authority to "repair" a tire includes the authority to service it with air (or nitrogen if required).

What you think is largely irrelevant, and judging from your rendering of the regulation, superfluous. I'll not argue the point at all, as no specific information is provided. You may not be able to remove the tire at all...let alone perform the required work. Assuming you have available the current maintenance publications for the tire, the wheel assembly, the landing gear, and the airframe--all from different sources--and you have the appropriate calibrated tools, approved materials, and the ability and training to perform the work to industry standard using all the practices and proceedures required by the approved data referenced, to the same standard expected of a certificated mechanic, you're still limited by complexity of operations, airworthiness directives, and other information you've probably not yet considered. Chances are that most often, you still can't legally perform the operations listed in Appendix A. This is often the case.

Once again, if you can't legally do it, and you do it, you've invalidated your airworthiness certificate. Read the fine print, as given in my prior posts.

Many wheel assemblies require numerous specific functions when changing a tire from the wheel assy...replacement of the wheel half packing, stripping the wheel assy, nondestructive testing such as zyglo or magnafluxing, and often magnetic particle inspection of the wheel bolts. This information usually isn't in your maintenance manual, which doesn't tell the whole story...it's often in the maintenance publications for the wheel assembly itself.

When you change that tire, do you bother to balance the tire, and do you know the standards and limitations in applying that balance? If you don't, you've invalidated your airworthiness certificate (remember line 6?). Do that and fly the aircraft, and you're flying an unairworthy aircraft, and are inviting a host of violations and penalties. You knew that too, right?

Lot's of AD's apply to refuelling.

Really? Which ones?

We better warn everybody to stop adding their own oil to their engines.

While you're warning them, you might add a warning that adding oil in many cases is indeed a maintenance function and requires a maintenance entry. You knew that, of course?

Plenty of "certified mechanics" have killed themselves by attaching unregulated 3000 psi nitrogen bottles to aircraft wheel assemblies.

Actually no, you'd find that to be an extremely rare occurence. More frequently, injuries or fatalities come from loosening the wheel halves prior to deflating the tire. It's an easy mistake to make. Additionally, damaged wheel assemblies, weakened bolts, boltheads, or threaded portions, serve to cause injury or death when inflating or deflating the tire. You have stats on the numbers of mechanics killed by using unregulated nitrogen, do you? Another one you pulled out of thin air to support a 100% incorrect point? Good grief. Read the regulation, get to know it a little bit, and then cry about it.

 

[Almerick07]

Nah, can't be.... who would want to waste thier beer that way?
Gryphon is offline Report Bad Post Reply With Quote

Im pretty drunk right now and have decided youre right....beer in tires and struts is a bad idea....unless avbug can prove me wrong

 

[ackattacker]

Once Again, AvGod has spoken and it appears very definitive. But was has he actually said?

Applying compressed gas to a wheel assembly isn't preventative maintenance, it's servicing, and it may or may not require a mechanic.

OK, we've established that "servicing a wheel" is not preventative maintenance but "repairing" a wheel is. It "may or may not require a mechanic". Depending upon what, exactly? Where does it say I can service a wheel, and where does it say I cannot? You seem hellbent to argue with anybody. I guess if I said I can do it I'm wrong and if I say I cannot I'm also wrong. The correct AvGod answer is maybe you can, if I you get permission from AvGod.

Upon what basis have you determined that servicing becomes maintenance, whereas "routine servicing" is not maintenance?

YOU are the one who claimed that applying compressed gas to a wheel assembly is servicing, but not repair. YOU find it in the regulations.

Items listed under Appendix A may or may not require the services of a certificated mechanic.

Wrong, items listed under Appendix A DO NOT require the services of a mechanic under part 91. That much is clear. And I am talking about legality, not whether or not the particular pilot in question has the proper manuals, tools, and skills.

The word "servicing" has no bearing on the topic, and does not define what constitutes preventative maintenance, nor does it have any bearing on what a pilot can or cannot do. Further, those terms, and your useage thereof, have no bearing upon their applicability to certificate operations such as Part 135.

Appendix A references "servicing" no less than 3 times. For example, it says that "Servicing landing gear shock struts by adding oil, air, or both" is preventative maintenance. And again, YOU are the one who rather authoritatively said that adding air to tires is "servicing". Clearly it does have some bearing and does define what a pilot can or cannot do.

Again, a concept you have dreamed up, with no basis in regulation or fact. Why exactly might a pilot not be able to add H-5606 fluid, yet be fully legal in adding Turbine Type II oil, instead?

Because, adding H-5606 is clearly defined in the regulations as an item of preventative maintenance but adding oil (Turbine or otherwise) is not. Clear enough?

Particularly with respect to maintenance items, a certificate holder may obtain authorization to enable a crewmember to perform almost any operation, so long as all the requirements to perform that operation are met and the operation is conducted in accordance with that authorization. This could include fluids, gasses, removal and installation of seats, panels, plugs, gauges, etc. The ability of a certificate holder to obtain this authorization lies in the abiity of the certificate holder to ask for it.

True. A certificate holder can obtain authorization for pilots to perform certain items of preventative maintenance. It does not need to obtain an authorization to do things like add oil, which is NOT an item of maintenance preventative or otherwise. I have added oil to a part 135 aircraft with an FAA PMI standing right in front of me, and I didn't have a waiver. I added air to the tire of a C172RG of my initial CFI checkride and the Fed helped me do it. I ain't loosing any sleep over it.

14 CFR 43.3(a) Except as provided in this section and §43.17, no person may maintain, rebuild, alter, or perform preventive maintenance on an aircraft, airframe, aircraft engine, propeller, appliance, or component part to which this part applies. Those items, the performance of which is a major alteration, a major repair, or preventive maintenance, are listed in appendix A.

14 CFR 1.1 (definitions)

Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.

Major repair means a repair:
(1) That, if improperly done, might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or
(2) That is not done according to accepted practices or cannot be done by elementary operations.

You may not be able to remove the tire at all...let alone perform the required work. Assuming you have available the current maintenance publications for the tire, the wheel assembly, the landing gear, and the airframe--all from different sources--and you have the appropriate calibrated tools, approved materials,

etc etc.

Irrelevent, as is the rest of your rambling about magnafluxing and so on. The question is the legality, not whether I understand the proper way to do it or have the tools.

Really? Which ones?

(referring to refuelling AD's)

here's one.

49-31-02 REPUBLIC: Applies to All Model RC-3 Airplanes.

Compliance required not later than October 1, 1949.

In order to eliminate the possibility of engine failures resulting from fuel starvation due to incorrect procedures of checking the fuel tank capacity, the following placard must be installed in the vicinity of the fuel tank filler neck:

"WARNING - Do not check fuel with engine running, or within 5 minutes after shutdown. Always insert stick with calibrated side facing ground."

While you're warning them, you might add a warning that adding oil in many cases is indeed a maintenance function and requires a maintenance entry. You knew that, of course?

Sure. It requires a maintenance entry under 121, because that's part of our approved maintenance program. It requires a maintenance entry if you have to remove a panel or cowl. Otherwise, it's not. It's routine servicing, no different then adding fuel.

Actually no, you'd find that to be an extremely rare occurence. More frequently, injuries or fatalities come from loosening the wheel halves prior to deflating the tire. It's an easy mistake to make. Additionally, damaged wheel assemblies, weakened bolts, boltheads, or threaded portions, serve to cause injury or death when inflating or deflating the tire. You have stats on the numbers of mechanics killed by using unregulated nitrogen, do you? Another one you pulled out of thin air to support a 100% incorrect point? Good grief. Read the regulation, get to know it a little bit, and then cry about it.

Interestingly, I learned about the dangers of filling tires with unregulated nitrogen bottles while searching for the AD which you mentioned, AD 87-08-09, which, incidentally, does not specify that it needs to be complied with by a mechanic, only that it needs to be incorporated into the air carrier's maintenance program. Anther one I pulled out of "thin air" to support a "100 % incorrect point"

http://www.boeing.com/commercial/aeromagazine/aero_05/textonly/m03txt.html

Thousands of airplane tires are inflated during routine maintenance each day around the world. On occasion, a mechanic or other ground service employee has been severely or fatally injured in an explosion caused by use of unregulated pressure from an air or nitrogen tank. The latest reported incident occurred in 1998 when a mechanic was inflating a nose wheel/tire assembly on a 737 airplane. A total of five similar incidents have been reported as the cause of severe injury or death to maintenance personnel

 

[Gorilla]

By regulated, I assume you guys refer to the act of placing a pressure regulator on a cylinder of Nitrogen, and not some legal status.

Anyone who uses a 3,000 PSI cylinder to directly inflate any tire should have their ticket revoked permanently. Stupid doesn't begin to describe such an act.

 

[ackattacker]

By regulated, I assume you guys refer to the act of placing a pressure regulator on a cylinder of Nitrogen, and not some legal status.

Anyone who uses a 3,000 PSI cylinder to directly inflate any tire should have their ticket revoked permanently. Stupid doesn't begin to describe such an act.

I'd say that some of the people that did try it already "got their ticket permanently revoked"... if you catch my meaning. If you read the link it does talk about how most high-pressure tires now incoporate high-pressure relief valves to guard against such stupidity.

 

[avbug]

OK, we've established that "servicing a wheel" is not preventative maintenance but "repairing" a wheel is. It "may or may not require a mechanic". Depending upon what, exactly? Where does it say I can service a wheel, and where does it say I cannot?

Why do you insist on being wrong about everything? We have established no such thing. What specific operation on what specific wheel assembly, using what references and what equipment, and by whom? Depending on the nature of the operation, mate.

Where does "it" say you can service a wheel or that you cannot? That would really depend on the operation involved now, wouldn't it? Your comprehension skills are low, as we see, but by now hopefully you've learned that multiple references must be used to make such a determination, and are case specific for your operation, and must be counterbalanced against your own qualifications, equipment, experience, and ability to comply...you did catch that, did you not?

YOU are the one who claimed that applying compressed gas to a wheel assembly is servicing, but not repair.

Negative. Wrong again. It would be either, or both, depending on the operation. Judging from your responses, you're best off staying clear of doing anything more complex than turning a phillips screwdriver, however.

Wrong, items listed under Appendix A DO NOT require the services of a mechanic under part 91. That much is clear. And I am talking about legality, not whether or not the particular pilot in question has the proper manuals, tools, and skills.

Again, you speak incorrectly about things which you do not understand. The nature of the operation determines if a mechanic certificate is required. Merely because an operation is listed in Appendix A does NOT mean you can do it as a pilot without a mechanic or repairman certificate. The operation must not involve complex disassembly (or reassembly). You must have and use and reference the current maintenance publications (all of them) while performing the operation. You must use all the tools, practices and proceedures called out by the maintenance publications. You must be able to perform the work to industry standards and the same standards called for in the pubs, to the same standards required of any mechanic, and you must execute all the relevant documentation, log entries, etc.

That merely because an operation is listed in Appendix A does not mean you can do it is common knowledge...except to you, apparently. Learn whence you speak then open your trap...you seem to be proud of ignorance. Don't be that way.

Appendix A references "servicing" no less than 3 times. For example, it says that "Servicing landing gear shock struts by adding oil, air, or both" is preventative maintenance. And again, YOU are the one who rather authoritatively said that adding air to tires is "servicing". Clearly it does have some bearing and does define what a pilot can or cannot do.

No, it really has no bearing, as the operation is the determining factor. Servicing an item may require a complex disassembly, and may prevent a non-repairman/non-mechanic from performing the job on his or her own. This may be as simple as changing a tire; numerous errors may be introduced in the simple changing of a wheel assembly on a light aircraft that can kill someone; the nature of the work, depending on the specific operation, may very well require a certificated and trained person. Servicing or not. In many cases, servicing is a maintenance function, though it's not a repair. Accessing something to service it, or the act of servicing it, is often a maintenance function that cannot and should not be performed by a non-certificated mechanic. Often to service a tire, brake disassembly and removal is required...the operation, if requiring more than merely sliding one wheel assembly off and another on, can quickly become a complex operation which you are not permitted to execute.

But of course you knew that, expert.

Because, adding H-5606 is clearly defined in the regulations as an item of preventative maintenance but adding oil (Turbine or otherwise) is not. Clear enough?

No, not clear enough at all. Adding H-5606 to a propeller assembly in an overservice proceedure...servicing with hydraulic fluid...is far outside your means, rights, or ability, but is servicing none the less. It may be listed in Appendix A, but that doesn't mean you can do it, and that doesn't require complex disassembly. Doing it incorrectly can result in blown seals, loss of propeller control, ultimately loss of engine control, as well as an operational inflight fire or flame-out. It's a simple operation, and it involves hydraulic fluid...but is an example of an operation that appears to be listed in Appendix A, but really isn't something you can or ought to do without specialized training and supervision, at a minimum.

Again, you do not understand the regulation in the least. You make the assumption (remember what happens when you make assumptions...it happens to you a lot, doesn't it?) that if something is listed in Appendix A you can automatically do it, and if it isn't listed, you can't. You're wrong on both counts.

You still fail to grasp that a quick reading of Appendix A doesn't make you informed on the subject of maintenance. Why do you suppose that years are required to make a mechanic, vs. merely reading a few paragraphs and going to work? More to the subject exists than what you find in Appendix A. Get it?